Can a police officer stop an Unregistered car without additional evidence that the driver is the owner?

In the 2020 case Kansas v. Glover 140 S. Ct. 1183 (2020), the U.S. Supreme Court clarified the balance between law enforcement’s use of reasonable suspicion and the protections against unreasonable searches and seizures.  The State of Kansas threw out an arrest based upon a traffic stop that was solely based upon the fact that the person who owned the car did not have a valid license.  The Court stated that only the car driver was not necessarily the car owner (whose registration was expired).  The Court reasoned that the stop was bad because it unfairly placed licensed driver's at risk.

Background of the Case

In Kansas, a sheriff’s deputy ran a license plate check on a pickup truck and discovered that the registered owner, Charles Glover, had a revoked driver’s license. Without observing any traffic violations or signs of impaired driving, the deputy stopped the truck to confirm whether Glover was driving. Upon verifying Glover’s identity, the deputy cited him for driving with a revoked license.

Glover challenged the stop, and the Kansas Supreme Court sided with him, ruling that the deputy lacked reasonable suspicion. The Kansas court argued that it was unreasonable to assume the driver was the registered owner, as many vehicles are driven by individuals other than their owners. Prosecutors appealed this decision to the U.S. Supreme Court.

The Legal Issue

The central issue in Kansas v. Glover was whether the deputy’s inference—that the driver of a vehicle is likely its registered owner—constitutes reasonable suspicion under the Fourth Amendment to justify a traffic stop when the officer knows the owner’s license is revoked.

The Fourth Amendment protects individuals from unreasonable searches and seizures, requiring officers to have specific, articulable facts to justify a stop. Reasonable suspicion, a lower standard than probable cause, allows officers to act based on commonsense judgments and inferences drawn from their training and experience. The question was whether the deputy’s assumption met this threshold.

The Supreme Court’s Reasoning

The U.S. Supreme Court overturned the Kansas Supreme Court’s decision, holding that the deputy’s stop was lawful. The Court emphasized several key principles:

Reasonable Inferences and Common Sense: The Court reaffirmed that reasonable suspicion does not require absolute certainty. Officers may rely on commonsense judgments and inferences about human behavior, as established in cases like Illinois v. Wardlow (2000). The deputy’s assumption that the registered owner was likely driving was reasonable, even if not always true.

Training and Experience: The Court noted that officers’ training and experience play a critical role in interpreting facts. In Illinois v. Gates (1983), the Court explained that evidence should be evaluated through the lens of law enforcement expertise, not academic analysis. The deputy’s decision to stop the truck was informed by this practical perspective.

Possibility of Innocent Explanations: The Court addressed the Kansas Supreme Court’s concern that many vehicles are driven by non-owners. Citing People v. Brown (1990), the Court clarified that the possibility of an innocent explanation does not negate reasonable suspicion. The officer’s role is to investigate and resolve such ambiguities.

The Supreme Court concluded that the deputy had reasonable suspicion to stop Glover’s truck, as the inference that the registered owner was driving was grounded in common sense and supported by the fact of the revoked license. The stop was therefore constitutional, and the Kansas Supreme Court’s ruling was reversed.

Implications of the Ruling

Kansas v. Glover reinforces the flexibility officers have in making reasonable inferences during investigations. It underscores that reasonable suspicion is a practical standard, not a rigid requirement for certainty. This decision has significant implications for law enforcement practices, particularly in the context of traffic stops based on license plate checks.

For the public, the ruling highlights the balance between individual rights and public safety. While it affirms officers’ ability to act on reasonable assumptions, it also emphasizes the importance of specific facts in justifying stops, ensuring that Fourth Amendment protections are not eroded.

Conclusion

The Kansas v. Glover decision clarifies that officers may rely on reasonable inferences, such as the likelihood that a vehicle’s driver is its registered owner, to establish reasonable suspicion for a stop. By grounding its ruling in established Fourth Amendment principles, the Supreme Court provided clear guidance for law enforcement while upholding constitutional protections.